Skip to content
BOL Conferences
Thread Options
#285096 - 12/06/04 10:48 PM Point me to the right threads
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
I am trying to determine what to do with loans that have farmland and a dwelling for both our CRA and HMDA loan registers. I know earlier in the year everyone seemed to think we couldn't double report but if I recall correctly that has kind of swayed to us having to double report them. I am having trouble doing searches for threads regarding the following:
Loans secured with farmland and dwellings
Meets a HMDA purchase or refinance definition
Meets a CRA small farm definition

Thank you!

Return to Top
Lending Compliance
#285097 - 12/06/04 10:51 PM Re: Point me to the right threads
someone else Offline
Power Poster
someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
check out the thread on this same page entitled "purchase of race horse farm with home".
_________________________
Somewhere, something incredible is waiting to be known. - Carl Sagan

Return to Top
#285098 - 12/06/04 11:09 PM Re: Point me to the right threads
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,842
I can't help with CRA, but for HMDA purposes use the following:

For purchase transactions if the applicant is buying the property to acquire a farm, and it includes a dwelling, it isn't reportable. If they are buying it to acquire a dwelling and it happens to include a farm, it is reportable.

For refinances, follow the same rule as any other loan. If a loan secured by a dwelling is satisfied by a new loan to the same borrower secured by a dwelling it is reportable.

Here, most purchases are not reportable and most refis are.

Return to Top
#285099 - 12/06/04 11:14 PM Re: Point me to the right threads
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
Ouch - headache coming on! So for purchases it is up to the lender to state if the borrowers intent is to buy a home or to buy farmland?? What if someone just built a $250,000 home on 50 acres and they are going to put cattle on it as well. How would the borrower themself even be able to answer that one way or the other?

Return to Top
#285100 - 12/06/04 11:18 PM Re: Point me to the right threads
someone else Offline
Power Poster
someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
That's the fun of HMDA!
_________________________
Somewhere, something incredible is waiting to be known. - Carl Sagan

Return to Top
#285101 - 12/06/04 11:24 PM Re: Point me to the right threads
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,842
We generally rely on the lender to provide as much information as we can get to help decide. You can use the 25 acre guideline for RESPA on a case by case basis(see pg D-6 of GIR). Sometimes we consider source of income (again on a case by case basis). In your example above, if the applicant has a 'day job' and wants the cattle for personal use, or as a small side business, I would report it. If they intend to support themselves from the sale of the milk (or meat, but I'm in a dairy state ), I would not report.

Return to Top

Moderator:  Andy_Z